ML20199D861
| ML20199D861 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 01/12/1999 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20199D859 | List: |
| References | |
| NUDOCS 9901200232 | |
| Download: ML20199D861 (15) | |
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p uog j g 4 UNITED STATES g j NUCLEAR REGULATORY COMMISSION g g WASHINGTON, D.C. 2066H001
%, . . . . . f l
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO INSERVICE INSPECTION PROGRAM RELIEF REQUESTS FOR l
l SOUTHERN NUCLEAR OPERATING COMPANY. INC.
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JOSEPH M. FARLEY NUCLEAR PLANT. UNITS 1 AND 2 DOCKET NOS. 50-348 AND 50-364 l
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1.0 INTRODUCTION
l The Technical Specifications (TS) for Joseph M. Farley Nuclear Plant (FNP), Units 1 and 2, state that the inservice inspection (ISI) of the American Society of Mechanical Engineers i (ASME) Code Class 1,2, and 3 components shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code (ASME Code) and applicable addenda as required by Title 10 of the Code of Federal Reaulations (10 CFR) Section 50.55a(g), except where specific written relief has been granted by the U.S. Nuclear Regulatory Commission i l (Commission or NRC) pursuant to 10 CFR 50.55a(6)(g)(l). Section 50.55a(a)(3) states that l l attematives to the requirements of paragraph (g) may be used, when authorized by the NRC, if
! (i) the proposed alternatives would provide an acceptable level of quality and safety or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a componsating increase in the level of quality and safety.
Pursuant to 10 CFR 50.55a(g)(4), ASME Code Class 1,2, and 3 components (including supports) shall meet the requirements, except the design and access provisions and the preservice examination requirements, set forth in the ASME Code,Section XI, " Rules for Inservice Inspection of Nuclear Power Plant Components," to the extent practical within the limitations of design, geometry, and materials of construction of the components. The regulations require that inservice examination of components and system pressure tests conducted during the first 10-year interval and subsequent intervals comply with the requirements in the latest edition and addenda of Section XI of the ASME Code incorporated by reference in 10 CFR 50.55a(b) 12 months prior to the start of the 120-month interval, subject to the limitations and modifications listed therein. The applicable ASME Code,Section XI, for the FNP Unit 1 third 10-year ISI program and the Unit 2 updated program, is the 1989 Edition.
Pursuant to 10 CFR 50.55a(g)(6)(i), if Southern Nuclear Operating Corrpany, Inc. (SNC/the licensee) determines that conformance with an examination requirement of Section XI of the ASME Code is not practical for its facility, information shall be submitted to the Commission in support of that determination and a request made for relief.
- Enclosure 1 9901200232 990112 PDR ADOCK 05000348 '
G PDR I
2.0 EVALUATION By letter dated May 28,1997, SNC submitted the RRs associated with the third 10-year interval ISI program for Farley Unit 1, and the updated ISI program for Farley Unit 2. The staff, with technical assistance from its contractor, the Idaho National Engineering and Environmental Laboratory (INEEL), has evaluated the information provided by SNC in support of its ISI program for RR-1 thru RR-26 and RR-28 thru RR-30 with the exception of RR-12, which was evaluated by the staff alone. RR-27 was previously authorized by letter dated January 22, 1998. Based on the results of the review, the staff has adopted the contractor's conclusions and recommendations presented in the Technical Evaluation Report INEEL/ EXT-98-01156 (Enclosure 2).
RR-1. Material Recuirements for Calibration Blocks Used For Ultrasonic Examination of Heavy Wall VesselsSection XI,1989 Edition, Article 1-2000, Paragraph l-2100 requires that ultrasonic examination of vessel welds in ferritic materials greater than 2 inches thick be performed in accordance with Article 4,Section V. Paragraph T-441.1.2.1, Article 4 requires that the material from which calibration blocks are fabricated be of the same material specification, product form, and heat treatment as one of the materials being joined. Pursuant to 10 CFR 50.55a(a)(3)(i), the licensee proposed the use of calibration blocks which comply with the material requirements of the 1974 edition of ASME Section V. The licensee has demonstrated acoustic compatibility of the ca'.ibration blocks in question with the components being examined and, further, these blocks have been utilized for examinations since the plant was built. Hence, continued use of these calibration blocks would provide consistent examination results and the proposed altemative would provide an acceptable level of quality and safety. Therefore, the proposed alternative is authorized pursuant to 10 CFR 50.55a(a)(3)(i).
RR-2, Notch Location Recuirements for Calibration Blocks Used or Ultrasonic Examination of Heavy Wall VesselsSection XI,1989 Edition, Article 1-2000, paragraph l-2100 requires that ultrasonic examination of vessel welds in ferritic materials greater than 2 inches thick (t) be performed in accordance l
with Article 4,Section V. Figure T-441.1, Article 4 requires that notches be 2 percent t deep with a tolerance of +10 percent -20 percent located a minimum of 3 inches from the edge and t/2 from the end of the block. Pursuant to 10 CFR 50.55a(a)(3)(i), the licensee proposed the use of calibration blocks with minor variations in dimensional requirements. The calibration j blocks in question have been utilized for examinations since the plant was constructed.
Therefore, continued use of these calibration blocks would provide consistent examination results. The licensee has determined the current notch locations have had no detrimental effect on calibrations. The licensee has also determined that any inaccuracy in calibration caused by slight variations in notch depth are within the accuracy of the ultrasonic testing technique and is significantly less than the 2 decibels or 20 percent correction allowed on the distance-amplitude correction curve. The licensee has demonstrated that continued use of subject calibration blocks will provice an acceptable level of quality and safety. Therefore, the proposed alternative is authorized pursuant to 10 CFR 50.55a(a)(3)(i).
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3-RR-3. Hole Location Reauirements for Calibration Blocks Used for Ultrasonic Examination of Heaw Wall VesselsSection XI,1989 Edition, Article 1-2000, Paragraph l-2100 requires that ultrasonic examination of vessel welds in ferritic materials greater than 2 inches thick be performed in accordance with Article 4,Section V. Figure T-441.1, Article 4 requires that aligned side-drilled holes be located at a minimum distance of t/2 from the end of the block where "t"is the block thickness. i Nonaligned holes are required to be located at a minimum of 1.5 inches from the end of the block. Side-drilled holes are required to be 1/4t,1/2t, and 3/4t 0.125-inch deep. Nonaligned holes are to have a minimum separation of t/4. Pursuant to 10 CFR 50.55a(a)(3)(i), the licensee proposed the use of calibration blocks with variations in hole location, depth, and/or separation requirements for calibration blocks used to perform ultrasonic examinations on l vessels greater than 2 inches thick. The calibration blocks in question have been utilized for examinations since the plant was constructed. Therefore, continued use of these calibration blocks would provide consistent examination results as compared with previous examinations.
The licensee, through successful calibrations, has demonstrated that minor variations of the l dimensional requirements of the hole locations has not diminished the ability to satisfy calibration requirements. Hence, continued use of the calibration blocks will provide an acceptable level of quality and safety. Therefore, the proposed alternative is authorized pursuant to 10 CFR 50.55a(a)(3)(i).
l RR-4. Dimensional Reauirements for Notches Placed in Ultrasonic Calibration BlocksSection XI,1989 Edition, Article 1-2000, Paragraph l-2200, Appendix 111, Paragraph lll-3430 requires that basic calibration blocks shall contain notches that are at least 1.0-inch long and 0.104t-0.009t 2+10 percent, -20 percent in depth where "t" is the block thickness.
Pursuant to 10 CFR 50.55a(a)(3)(i), the licensee proposed the use of ALA-21, ALA 23, ALA-26, and ALA 28 calibration blocks with minor variations in dimensional requirements. The subject calibration blocks contain notches that are smaller than those required by the Code. The undersize notches in the calibration blocks would provide a more sensitive examination. The subject calibration blocks have been in use since the plant was constructed. The continued use of the calibration blocks would provide a more consistent comparison to previous examinations.
The licensee has also demonstrated the ability to successfully calibrate utilizing the subject calibration blocks. Hence, the continued use of the subject calibration blocks will provide an acceptable level of quality and safety. Therefore, the proposed alternative is authorized pursuant to 10 CFR 50.55a(a)(3)(i).
RR-5. Curvature Differences Between Ultrasonic Calibration Blocks and the Components to be Examined ,
Section XI,1989 Edition, Article 12000, Paragraph I-2200, Appendix lil, Paragraph 1113410 requires that basic calibration blocks shall be made from material of the same nominat diameter as the pipe to be examined. Pursuant to 10 CFR 50.55a(a)(3)(i), the licensee proposed the use of calibration block ALA-25 with minor variations in dimensional requirements. The subject calibration block has been utilized for examinations since the plant was constructed. Therefore, continued use of these calibration blocks would provide consistent examination results when compared with previous examinations. The licensee, through successful calibrations, has
demonstrated that the diameter variation has not diminished the ability to satisfy calibration requirements. Hence, the continued use of the subject calibration blocks will provide an acceptable level of quality and safety. Therefore, the proposed alternative is authorized pursuant to 10 CFR 50.55a(a)(3)(i).
RR-6. Revision 1. Examination Cateoorv B-D. Item B3.110. Pressurizer Nozzle-to-Vessel WeldsSection XI, Table IWB-2500-1, Examination Category B-D, item B3.110 requires a 100 percent volumetric examination of the pressurizer nozzle-to-vessel welds as defined by Figure IWB-2500-7(b).
Pursuant to 10 CFR 50.55a(g)(6)(i), the licensee requested relief from examining 100 percent of the Code-required volume of the pressurizer nozzle-to-vessel welds. The configuration of the pressurizer nozzles are such that the Code-required 100 percent coverage cannot be achieved and is, therefore, impractical. In order to examine the welds in accordance with the requirements, the pressurizer nozzles would have to be redesigned, fabricated, and installed.
The licensee states that approximately 73 percent composite coverage can be obtained for the welds in question. The licensee will perform a supplemental surface examination to provide further verification of the structuralintegrity of the welds in question. The proposed alternative to perform a best-effort ultrasonic examination and supplementing it with a surface examination, will provide reasonable assurance of continued structuralintegrity of the pressurizer nozzle-to-vessel welds. Therefore, relief is granted and the alternative imposed pursuant to 10 CFR 50.55a(g)(6)(i).
RR-7. Revision 1. Examination Cateoorv B-F. Item B5.70. Steam Generator (SG) Nozzle-to-Safe End Butt WeldsSection XI, Table IWB-2500-1, Examination Category B-F, item B5.70 requires both 100 percent volumetric and surface examination of the SG dissimilar metal nozzle-to-safe end butt welds as defined by Figure IWB-2500-8. Pursuant to 10 CFR 50.55a(g)(6)(i), the licensee requested relief from examining 100 percent of the Code-required volume of the SG nozzle (with weld deposited safe-end) to pipe welds due to nozzle geometry and clad overlay, which limits scanning of the welds. The licensee has determined that the composite examination coverage obtainable is 50 percent. The staff finds that the requirements of the Code are impractical due to physical obstructions. Imposition of the Code would require design modifications that would result in a burden upon the licensee. The proposed alternative to perform the ultrasonic examinations to the maximum extent practical with the Code-required surface examination will provide reasonable assurance of structuralintegrity of the subject SG nozzle-to-safe end butt welds. Therefore, relief is granted pursuant to 10 CFR 50.55a(g)(6)(i).
RR-8. Revision 1. Examination Cateoorv B-D. Item B3.140. SGs (Primary Side) Nozzle Inside Radius Sectio _n Section XI, Table IWB-2500-1, Examination Category B-D, item B3.140 requires a 100 percent volumetric examination of the SG (primary side) nozzle insids radius sections as defined by Figure IWB-2500-7.
Pursuant to 10 CFR 50.55a(g)(6)(i), the licensee requested relief from performing volumetric examination of the SGs primary side inlet and outlet inner radius sections. The requirement of
the Code is impractical because the SG nozzle inner radius section cannot be volumetrically examined from the outside of the nozzle or channel head because the rough, as-cast contact surface is not suitable for ultrasonic coupling and the geometrical configuration requires an excessively long test metal distance resulting in high ultrasonic attenustion. In order to meet the Code requirement, the SG nozzles would reovire replacement, which is impractical and would impose a burden on the licensee. The licensee has proposed to perform a VT-1 visual examination of the nozzle inside radius sections. The proposed alternative to perform a visual examination on the inside surface of each SG primary side nozzle inner radius section will provide reasonable assurance of structuralintegrity of the subject SG nozzle inner radius regions. Therefore, relief is granted pursuant to 10 CFR 50.55a(g)(6)(i).
RR-9. Revision 1. Examination Cateaorv B-J. Item B9.31. Branch Pioe Connection Welds NPS 4 or Laraer Section XI, IWB-2500-1, Examination Category B-J, item B9.31 requires both 100 percent volumetric and surface examinations of the Class 1 branch pipe connection welds nominal pipe size 4 inches and greater as defined by Figures IWB-2500-9, -10, -11.
Pursuant to 10 CFR 50.55a(g)(6)(i), the licensee requested relief from examining 100 percent of the Code-required volume of retaining branch connections located on the centrifugally cast stainless steel, main loop piping welds. The configuration of the branch connections is such that the Code required 100 percent coverage cannot be achieved and is therefore impractical.
In order to examine the welds in accordance with the requirements of the Code, the branch connections, in conjunction with portions of the main loop piping, would have to be redesigned, which would impose a burden on the licensee. A best-effort volumetric examination of the welds in conjunction with the Code-required surface examination will provide reasonable assurance of structuralintegrity of the welds. Imposition of the Code requirement would require design modifications that would result in a burden on the licensee. Therefore, relief is granted pursuant to 10 CFR 50.55a(g)(6)(i).
RR-10. Revision 1. Examination Cateaorv C-B. Item C2.22. Nozzle Inside Radius Section Section XI, Table IWB-2500-1, Examination Category C-B, item C2.22 requires a 100 percent volumetric examination of the nozzle inside radius sections of nozzles in Class 2 vessels greater than one-half inch nominal wall thickness as defined by Figure IWB-2500-4(a) or (b).
Pursuant to 10 CFR 50.55a(g)(6)(i), the licensee requested relief from performing the Code required volumetric examination of the SG outlet nozzle inside radius section. The steam outlet nozzle was designed with an internal multiple hole type flow restrictor. This design does not use a radiused nozzle as described in Figure IWC-2500 4, but instead has several individual inner radii, corresponding to each hole. Therefore, the Code requirement is not ,
applicable for the design of the nozzle and is, therefore, impractical to perform. Imposition of the Code requirement would require design modifications that would result in a burden on the licensee. Therefore, relief is granted pursuant to 10 CFR 50.55a(g)(6)(i).
RR-11. IWA-2610. Reference System for All Welds and Areas Subiect to Volumetric and Surface Examination l
f Section XI, Paragraph IWA-2610, requires that a reference system shall be established for all l welds and areas subject to surface or volumetric examination. Each such weld and area shall
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- be located and identified by a system of reference points. The system shall permit identification i
! of each weld, location of each weld center line, and designation of regular intervals along the i length of the weld.
l Pursuant to 10 CFR 50.55a(a)(3)(ii), the licensee proposed an alternative to apply the required j markings as the ISI examinations are performed. The staff has determined that for FNP,
- Units 1 and 2, the marking of all welds subject to volumetric or surface examination to establish
! a reference system for welds in the absence of examination is a hardship or unusual difficulty
. without a compensating increase in the level of quality and safety since the alternative provides l reasonable assurance. Therefore, the licensee's proposed attemative is authorized pursuant to j 10 CFR 50.55a(a)(3)(ii).
RR-12. lWF-5000 Visual Examination and Functional Testina of Snubbers Article IWF-5000 provides inservice inspection requirements for snubbers, with regard to visual examination and functional testing of snubbers. Article IWF-5000 references the first addenda to ASME/ ANSI OM-1987, Part 4 (OM-4) for such snubber activities. The licensee requested the continued use of the current TS requirements for snubber visual examination and functional i testing, pursuant to 10 CFR 50.55a(a)(3)(l).
The licensee stated, in its submittal, that the current FNP TS specifies an adequate program for visual examination and functional testing for all safety-related snubbers. The snubber examinations and testing at FNP, Units 1 and 2 are currently performed under TS l Section 3/4.7.9, which is in accordance with NRC Generic Letter (GL) 90-09, " Alternative Requirements for Snubber Visual Inspection Intervals and Corrective Actions,' dated December 11,1990. The licensee stated that the current inspection program as defined by the TS provides for a level of quality and safety equal to or greater than that of the OM-4. This is based on the fact that the alternative provides the same confidence level, as supported by GL 90-09. Furthermore, the TS snubber progt em scope includes all safety-related snubbers, which encompasses all Code Class 1,2, and 3 snubbers that meet the ASME Section XI requirements. l l
The licensee further stated that the fist addenda to ASME/ ANSI OM-1987, Part 4, was an early I attempt to involve the nuclear industry in the development of a standard for testing snubbers. l Beginning in 1990, OM Standards involving snubber testing were codified into the ASME OM !
Code (Section ISTD). Considerable work has been performed by the OM Code representatives l from utilities (of which the licensee is a major participant), vendors, and NRC to enhance the requirements for testing snubbers while ensuring the adequacy of the testing. However, as with the development of any ASME Code, the evolution has taken place over several years. The licensee recognizes that additional work remains to be performed to improve Subsection ISTD; l however, the licensee believes that these later Codes are much improved over the first i addenda to ASME/ ANSI OM-1987, Part 4. Based on the above, the licensee contends that implementation of the 10-year-old ASME/ ANSI OM 1987, Part 4, at FNP would be a regressive j step.
The NRC staff has reviewed the licensee's submittal pertaining to the relief request from the requirements of the ASME Code for visual examination and functional testing of snubbers. The FNP TS requires that, at least once every 18 months during shutdown, a representative sample of 88 snubbers shall be functionally tested. If more than three snubbers do not meet the I
functional test criteria, additional testing will be performed. In addition, the licensee stated that the 1989 Edition of the ASME Code,Section XI, will continue to be used for repair and replacement activities for snubbers. The licensee contends that continued use of the existing TS snubber examination and testing program at FNP, Units 1 and 2 will provide a sustained continuity while Subsection ISTD is being revised, and will provide assurance that snubbers will function and protect the structuralintegrity of safety-related systems and components at FNP, Units 1 and 2. The NRC staff agrees with the licensee's position.
The licensee indicated that personnel qualification for snubber inspection and testing performed in accordance with TS 3/4.7.9 is done under the site administrative procedure, FNP-0-AP-31, Quality Control Measures. The licensee also provided for staff review the FNP Nondestructive Examination Procedure, FNP-0-NDE-100.23, which defines the requirements for VT-3 visual examination to determine the general mechanical and structural condition of components and their supports. This procedure is developed to comply with the requirements of the ASME Code,Section XI,1989 Edition. The VT-3 visual examination includes examinations for conditions that could affect operability or functional adequacy of snubbers. This is acceptable to the NRC staff.
Based on the information provided, the NRC staff has determined that the licensee has presented an adequate justification for relief from the requirements of ASME Code 1989 Edition,Section XI, Article IWF-5000 (which references OM-1987, Part 4), with regard to visual examination and functional testing of safety-related snubbers. The proposed alternative use of the TS requirements in Section 3/4.7.9 provides assurance of snubber operability and, thus, provides an acceptable level of quality and safety. Therefore, the proposed alternative is authorized pursuant to 10 CFR 50.55a(a)(3)(i),
l RR-13. Revision 1. Examination Cateaorv B-G-1. Item B6.10. Reactor Pressure Vessel (RPV) !
Closure Head NutsSection XI, Table IWB-2500-1, Examination Category B-G-1, item B6.10 requires a surface examination of the Reactor Vessel Closure Head Nuts each 10-year interval.
Pursuant to 10 CFR 50.55a(a)(3)(i), the licensee proposed to r.>e f 7 a VT-1 Visual Examination in lieu of the required surface examination. The r .P .. rmined that the governing Code, which is the 1989 Edition, has no acceptan.r N r a the Code-required I examination as they were in the course of preparation when tN ' + was published. Without l clearly-defined acceptance criteria, conditions that require corre w raeasures may not be l adequately addressed. However, the 1989 Addenda to ASME Code,Section XI addresses these problems by changing the requirement for the subject reactor pressure vessel closure head nuts from surface to VT-1 visual examination and providing appropriate acceptance criteria and assurance of structuralintegrity. The staff, therefore, has determined that the VT-1 '
visual examination on reactor pressure vessel closure head nuts will provide an acceptable level of quality and safety. Therefore, the proposed alternative of conducting VT-1 visual examination in lieu of surface examination for closure head nuts is authcrized pursuant to 10 CFR 50.55a(a)(3)(i).
RR-14. Revision 1. lWC-1220 Comoonents Exemot From Examination Section XI, IWC-1220, Components Exernpt From Examination, provides exemption criteria for vessels, pumps, valves and their connections in piping with a nominal pipe size of 4 inches and smaller (excluding high pressure safety injection).
Pursuant to 10 CFR 50.55a(a)(3)(i), the licensee proposed to implement IWC-1220, from the 1989 Addenda of ASME Section XI, thereby exempting components from volumetric and surface examinations on vessels (including small diameter vessels fabricated essentially from piping) and their supports in Class 2 piping 4-inch nominal pipe size and smaller, in systems other than Residual Heat Removal, Emergency Core Cooling, or Containment Heat Removal systems or portions thereof. The specific components are as follows:
Letdown Delay Tanks Regenerative Heat Exchanger Excess Letdown Delay Tanks Excess Letdown Heat Exchanger Letdown Heat Exchanger Seal Water Return Filter Seal Water Heat Exchanger Volume Control Tank Reactor Coolant Filter Letdown Reheat Heat Exchanger The staff has determined that the licensee's proposed alternative, to use the exemption criteria of the 1989 Addenda and subsequent editions / addenda will provide an acceptable level of quality and safety by providing assurance of structural integrity for all of the subject components except for the Volume Control Tank (VCT) and the regenerative heat exchanger (RHE).
Therefore, the licensee's proposed alternative is authorized pursuant to 10 CFR 50.55a(a)(3)(i) for all of the subject components with the exception of the VCT and the RHE.
RR-15. Revision 1. Examination Cateoory C-C. Item C3.30. Intearally Welded Attachments on Charaina PumosSection XI, Table IWC-2500-1, Examination Category C-C, item C3.30 requires a surface examination of 100 percent of the required areas of each welded attachment of Class 2 pumps as defined by Figure IWC-2500-5.
Pursuant to 10 CFR 50.55a(g)(6)(i), the licensee requested relief from examining 100 percent of the Code-required surface of the charging pumps integrally welded attachments. The surface examination of the charging pump integrclly welded attachments is impractical to perform at FNP, Units 1 and 2, to the extent required by the Code because of the component configuration, location of the integral attachments, and the design of the supports. Imposition of the Code would require design modifications that would result in a burden on the licensee.
The licensee will perform surface examinations to the maximum extent possible that will provide reasonable assurance of structuralintegrity of the subject welded attachments. Therefore, relief is granted pursuant to 10 CFR 50.55a(g)(6)(i).
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RR-16. Revision 1. Examination Cateaorv B-D. Item B3.90. Reactor Pressure Vessel (RPV)
Nozzle-to-Vessel WeldsSection XI, Table IWB-2500-1, Examination Category B-D ltem 33.90 requires a volumetric examination of RPV nozzle-to-vessel welds as defined by Figum IWB 2500-7(a) and (b). The examination volume includes 100 percent of the weld length. Additionally,Section XI, Article I 2100 requires that ultrasonic examination of vesse' welds greater than 2 inches in thickness be conducted in accordance with ASME Code,Section V, Article 4. Article 4 requires a two-directional coverage wherever feasible.
Pursuant to 10 CFR 50.55a(g)(6)(i), the licensee requested relief from examination coverage for reflectors oriented transverse to the weld for the RPV nozzle to-vessel welds. The volumetric examinations of the subject nozzle-to-vessel welds in the RPV are impractical to perform at FNP, Unit 1 and Unit 2, to the extent required by Section XI of the ASME Code because of the geometric configuration of the nozzles. To meet the Code requirements, the nozzle-to-vessel welds would require refabrication, which would impose a burden on the licensee. The performance of the ultrasonic examinations, to the maximum extent practicel, from the nozzle bore and from the RPV inside diameter surface will provide reasonable assurance of structural integrity of the RPV nozzle-to-vessel welds. Therefore, relief is granted pursuant to 10 CFR 50.55a(g)(6)(i).
RR-17. Revision 1. Examination Cateaorv B-A. Item No. B1.30. Reactor Pressure Vessel Shell-to-Flanae Weld Section XI, Table IWB-2500-1, Examination Category B-A, item B1.30 requires a volumetric examination of the RPV shell-to-flange weld. The applicable examination volume is shown in Figure IWB-2500-4 and the examination volume includes essentially 100 percent of the weld length.
Pursuant to 10 CFR 50.55a(g)(6)(i), the licensee requested relief from volumetric examination of the RPV shell-to-flange weld to the extent required by the Code. Specifically, relief is requested from exemination coverage for reflectors oriented transverse to shell-to flange Weld ALA1-1100-1 for Unit 1, and Weld APR1-1100-1 for Unit 2. Due to a taper in the flange, the ability to scan for indications transverse to the shell-to-flange weld is limited. The staff has determined that it is impractical to examine the subject welds to the extent required by the Code. To obtain the complete coverage required by the Code, design modification of the RPV flange assembly, or redesign of automated inspection equipment by the nondestructive examination vendor would be necessary, which would impose a burden on the licensee. Based upon the percent of volumetric coverage obtainable, it is reasonable to conclude that a pattern of degradation, if present, will be detected. Therefore, relief is granted pursuant to 10 CFR 50.55a(g)(6)(i). '
RR-18. Use of Code Case N-521. Altemative Rules for Deferral of insoections of Nozzle-to Vessel Welds. Inside Radius Sections. and Nozzle to-Safe End Welds of Pressurized Water Reactor (PWR) VesselsSection XI, Table IWB 2500-1, Examination Category B-D, items B3.90 and B3.100, Examination Category B-F, item B5.10 require a 100 percent volumetric examination of all reactor vessel nozzle to-shell welds and nozzle inner radius sections and nozzle to-safe end
butt welds during each inspection interval as defined by Figures IWB-2500-7 and IWB-2500-8.
At least 25 percent but not more than 50 percent (credited) of the nozzles shall be examined by the end of the first inspection period and the remainder by the end of the inspection interval.
Pursuant to 10 CFR 50.55a(a)(3)(i), the licensee proposed the alternative requirements contained in Code Case N-521, Alternative Rules for Deferral of Inspections of Nozzle-to-Vessel Welds, inside Rades Sections, and Nozzle-to-Safe End Welds of a PWR Vessel,in lieu of the examination requirements of the 1989 Edition of the ASME Code,Section XI and defer examination of these areas until the end of the third 10-year interval. The licensee has met (or will meet for Unit 2) all of the conditions stated in Code Case N-521, and has examined all of the affected areas during the third period of the second interval, and hence, a new sequence of examinations has been established. The licensee has stated that the time between examinations will not exceed 10 years. Hence, the licensee's proposed alternative will provide an acceptable level of quality and safety by providing assurance of structural integrity.
Therefore, the licensee's proposed alternative is authorized pursuant to 10 CFR 50.55a(a)(3)(i).
The use of Code Case N 521 is authorized for the third 10-year interval at FNP Unit 1 and for the duration of the Unit 2 updated interval, or until the Code Case is approved for general use by reference in RG 1.147. At that time, the licensee may continue to use the Code Case with the limitations, if any, listed in RG 1.147.
RR-19. Use of Code Case N-524. Alternative Examination Reauirements for Lonaitudinal Welds in Class 1 and 2 Pioina Section XI, IWC-2500-1, Examination Category C-F-1, items C5.12 and C5.22 require a surface and volumetric examination of the longitudinal weld 2.St in length at the intersecting circumferential weld, [(t) being the thickness of the pipe examined]. Examination Category C-F-2, items C5.52 and C5.62 require a surface and volumetric examination of the longitudinal weld 2.St in length at the intersecting circumferential weld.
Pursuant to 10 CFR 50.55a(a)(3)(i), the licensee proposed to use the alternative requirements contained in Code Case N-524 in lieu of the specified Code requirements, for all Class 2 piping.
The staff has determined that the use of Code Case N-524 for Class 2 piping provides an acceptable level of quality and safety by providing assurance of structuralintegrity. Therefore, the licensee's proposed alternative, to use Code Case N-524 for Class 2 piping, is authorized pursuant to 10 CFR 50.55a(a)(3)(i). The use of Code Case N-524 is authorized for the third 10-year interval at FNP Unit 1 and for the duration of the Unit 2 updated interval, or until the Code Case is approved for general use by reference in RG 1.147. At that time, the licensee must follow the conditions, if any, specified in the RG.
RR-20. Revision 1. Use of Code Case N-509. Alternative Rules for the Selection and Examination of Class 1. 2. and 3 Intearally Welded AttachmentsSection XI, Examination Categories B-H, B-K-1, and C-C require volumetric or surface examinations of 100 percent of the nonexempt integrally welded attachments. Examination Categories D-A, D-8, and D-C, require visual examinations of 100 percent of the nonexempt integrally welded attachments. Pursuant to 10 CFR 50.55a(a)(3)(i), the licensee proposed to use the alternative requirements contained in Code Case N 509 in lieu of the specified Code requirements. The licensee's alternative also includes supplementing the Code Case with a minimum examination sample of 10 percent of allintegral attachments to non exempt Class 1,
l 2, and 3 components. The staff has determined that the alternative, to use Code Case N-509 with the minimum sample size of 10 percent of all nonexempt Class 1,2, and 3 integrally welded attachments, will provide assurance of structuralintegrity and, thus, provides an acceptable level of quality and safety. Therefore, the licensee's proposed alternative to use Code Case N-509 is authorized pursuant to 10 CFR 50.55a(a)(3)(i). The use of Code Case N-509 is authorized for the third 10-year interval at FNP Unit 1 and for the duration of the Unit 2 updated interval, or until the Code Case is approved for general use by reference in RG 1.147.
At that time, the licensee must follow the conditions, if any, specified in the RG.
RR-21. Use of Code Case N-408-1. Alternative Rules for 10-Year System Hvdrostatic Testina for Class 1. 2. and 3 Systems Pursuant to 10 CFR 50.55a(a)(3)(i), the licensee proposed to use the alternative requirements contained in Code Case N-498-1 in lieu of the required Code examination. The staff has determined that the licensee's proposed alternative, to use Code Case N-498-1, for Class 1,2, and 3 systems will provide assurance of structuralintegrity and, thus, provide an acceptacle level of quality and safety. Therefore, use of Code Case N-498-1 is authorized pursuant to 10 CFR 50.55a(a)(3)(i). The use of Code Case N-498-1 is authorized for the third 10-year interval at FNP Unit 1 and for the duration of the Unit 2 updated interval, or until the Code Case is approved for general use by reference in RG 1.147. At that time, the licensee must follow the conditions, if any, specified in the RG.
RR-22. Use of Code Case N-416-1. Alternative Pressure Test Reauirement for Welded Reoairs or installation of Replacement items by Weldina. Class 1. 2. and 3 Section XI components require a hydrostatic pressure test after welded repairs or installation of replacement items by welding, as noted in IWA-4000. Pursuant to 10 CFR 50.55a(a)(3)(i), the licensee proposed to use the alternative requirements contained in Code Case N-416-1 in lieu of the required Code examination. In addition, the alternative includes supplementing the pressure test with an additional surface examination on the root pass layer of Class 3 repair /
replacement welds or welded areas. The staff has determined that the licensee's proposed altemative, to use Code Case N-416-1 with a supplemental surface examination on the root pass layer of butt and socket welds, will provide assurance of structural integrity and, thus, provides an acceptable level of quality and safety. Therefore, the alternative is authorized pursuant to 10 CFR 50.55a(a)(3)(i). The use of Code Case N-416-1 is authorized for the third 10-year interval at FNP Unit 1 and for the duration of the Unit 2 updated interval, or until the Code Case is approved for general use by reference in RG 1.147. At that time, the licensee must follow the conditions, if any, specified in the RG.
RR-23. Revision 1. IWA-5250(a)(2). Corrective Measures for Bolted ConnectionsSection XI, IWA-5250(a)(2) requires that if leakage occurs at a bolted connection in ASME Section XI components, the bolting shall be removed, VT-3 examined for corrosion, and evaluated in accordance with IWA-3100.
Pursuant to 10 CFR 50.55a(a)(3)(i), the licensee proposed to use alternative requirements regarding corrective actions for leakage at bolted connections in lieu of the examination requirements as defined in IWA 5250(a)(2). The licensee has proposed an evaluation to determine its susceptibility to corrosion. The proposed evaluation will consider, as a minimum, ,
bolting materials, the corrosive nature of the process fluid, the leakage location and history, the service age of the botting materials, and visual evidence of corrosion at the assembled connection. The staff has determined that the licensee's proposed alternative to the requirements of IWA 5250(a)(2) is a conservative and technically sound engineering approach and, therefore, will provide an acceptable level of quality and safety. Therefore, the licensee's proposed alternative is authorized pursuant to 10 CFR 50.55a(a)(3)(i).
RR-24. Examination Cateaorv C-H. Hydrostatic Testina of Charoina Pumo Suction Pioina From the CVCS Boric Acid Blender. Boric Acid Filter. and Chemical Mixina Tank ASME Section XI, IWC-2500-1, Examination Category C-H requires pressure testing of Class 2 components in accordance with IWC-5221 and IWC-5222.
Pursuant to 10 CFR 50.55a(a)(3)(ii), the licensee proposed to perform VT-2 visual examinations, once each inspection period at normal operating pressure for the charging pump suction piping from each of the above components. The design of the suction piping incorporates check valves that prevent flow from the test fill point to the specified boundary valves. The location of the check valves, therefore, precludes pressurization of these portions of piping to Class 2 requirements. The licensee has stated that a visual examination (VT-2) will be performed on the subject piping segments during each inspection period in conjunction with the CVCS pressure tests while at normal operating pressure with the valves in their normal position. The staff has determined that compliance to the Code requirement would result in hardship to the licensee without a compensating increase in the level of quality and safety and since the proposed test provides reasonable assurance of structuralintegrity of the subject piping segments, the proposed alternative is authorized pursuant to 10 CFR 50.55a(a)(3)(ii).
RR-25. Class 3. lWA-5244(b) Buried Portions of Service Water System Pioina ASME Section XI, Paragraph IWA-5244(b) requires that in redundant systems where the buried components are non-isolable, the visual examination VT-2 shall consist of a test that determines the change in flow between the ends of the buried components. In cases where an annulus surrounds the buried components, the areas at each end of the buried components shall be visually examined for evidence of leakage in lieu of the flow test.
Pursuant to 10 CFR 50.55a(a)(3)(ii), the licensee proposed to perform a visual examination of the ground surface in lieu of the flow test as required by IWA-5244(b) for the buried portions of piping in the Service Water System (SWS). The design of the SWS does not provide instrumentation on the downstream side to measure the flow rate to perform the Code-required test. The staff has determined that compliance to the Code requirement would result in 1 hardship to the licensee without a compensating increase in quality and safety. The licensee's proposed alternative to visually inspect ground surface above the buried piping with the system in operation provides reasonable assurance of operational readiness. Therefore, the proposed alternative is authorized pursuant to 10 CFR 50.55a(a)(3)(ii), until the end of the first period of the third inspection interval for each unit of FNP.
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RR-26. ASME Class 1. Small Diameter (s 1 inch). Reactor Coolant System (RCS) Pressure Boundarv Vent and Drain Connections ASME Section XI, IWB-2500-1, Examination Category B-P, items B15.51 and B15.71 require the system hydrostatic test to include all Class 1 components within the system boundary.
Pursuant to 10 CFR 50.55a(a)(3)(ii), the licensee proposed to perform the Class 1 system hydrostatic test with the vent and drain valves in the closed position stating that the RCS vent and drain connections will be visually examined with the isolation valves in the normally closed position during each refueling outage for leakage and evidence of past leakage during the ASME XI Class 1 system leakage test. The licensee has further stated that the RCS vent and drain connections will also be visually examined with the isolation valves in the normally closed position during the 10-year hydrostatic test. In order for the licensee to perform the Code-required test, it would be necessary to manually open the inboard valve to pressurize the line segment. Pressurization by this method would defeat the RCS double isolation and may cause safety hazards for the personnel performing the examination. Moreover, manual actuation (opening and closing) of these valves, which are in close proximity to the RCS main loop, would expose plant personnel to approximately 1.2 man-rem per test. The staff has determined that compliance to the Code requirement would result in hardship without a compensating increase in the level of quality and safety. The licensee's proposed alternative will provide reasonable assurance of structural integrity of line segments and therefore, is authorized pursuant to 10 CFR 50.55a(a)(3)(ii).
l RR-28. Use of Code Case N-522. Pressure Testina of Containment Penetration Pioina ASME Section XI, Table IWC-2500-1, Category C-H requires pressure testing of all Class 2 pressure retaining components in accordance with IWC-5221 and IWC-5222.
I Pursuant to 10 CFR 50.55a(a)(3)(i), the licensee proposed to use the alternative requirements contained in Code Case N-522, Pressure Testing of Containment Penetration Piping, stating that FNP will perform Appendix J testing on the penetrations listed in Table 1 of its submittal, commensurate with the alternatives included in Code Case N-522. Leak rate testing of the subject penetrations will be performed at peak calculated containment ' pressure in accordance with 10 CFR Part 50, Appendix J, Option B. The tests will be scheduled per Appendix J, Option B at a frequency not to exceed 60 months. The staff finds that an acceptable level of quality and safety will be provided by Appendix J tests, when the leak test is performed at the peak calculated containment pressure and the test procedure provides for detection and location of through-wallleaks and the tests conducted at a frequency not to exceed 60 months.
Therefore, the proposed alternative is authorized pursuant to 10 CFR 50.55a(a)(3)(i). The use of Code Case N-522 is authorized for the third 10-year interval at FNP Unit 1 and for the duration of the Unit 2 updated interval, or until the Code Case is approved for general use by reference in RG 1.147. At that time, the licensee must follow the conditions, if any, specified in the RG.
RR-29. lWA 5244(b) and (c). Concrete Encased Portions of Soent Fuel Pool Coolina System Pioina Adiacent to Soent Fuel Pit ASME XI, Paragraph IWA-5244(b) requires that in redundant systems where buried components are nonisolable, the VT-2 visual examination shall consist of a test that determines the change in flow between the ends of the buried components. lWA-5244(c) requires that in
nonredundant systems where the buried components are nonisolable, such as return lines to the heat sink, the VT-2 shall consist only of verifying that the flow during operation is not impaired.
Pursuant to 10 CFR 50.55a(a)(3)(ii), the licensee proposed to visually examine the piping sections adjacent to the concrete encased piping in lieu of the flow test as required by IWA 5244(b) and (c) since the spent fuel pool system does not incorporate any flow measuring instrumentation on the suction piping, or any means of observing flow from the retum line. The staff, therefore, has determined that compliance to the Code requirement would result in hardship to the licensee without a compensating increase in the level of quality and safety. The proposed attemative to visually examine the piping sections adjacent to the concrete encased piping for potential leakage will provide reasonable assurance of operational readiness.
Therefore, the proposed attemative is authorized pursuant to 10 CFR 50.55a(a)(3)(ii).
RR-30. Examination Cateaorv CH. IWC-5222. Pressure Testina of Safety Iniection Svstem Pioina Seaments Which Are Nonisolable From Class 1 Pioina ASME XI, Table IWC-2500-1, Category C-H requires pressure testing of Class 2 pressure retaining components in accordance with IWC-5221 and IWC-5222.
Pursuant to 10 CFR 50.55a(g)(6)(i), the licensee requested relief from performing the hydrostatic pressure test at the required pressure since the system, as designed, has no provision for isolating the subject Class 2 piping segments from the Class 1 system to perform Code-required pressure testing. The boundary valves between the Class 1 and the Class 2 piping consist of check valves that allow flow to the RCS. The licensee's proposed altemative is to include the subject Class 2 piping segments within the VT-2 visual examination boundary of the Class 1 system leakage test performed during each refueling outage. In addition, the licensee will pressurize the piping segments to nominal RCS operating pressure during the 10 year hydrostatic test of the Class 1 system. The staff has determined that the proposed test will provide reasonable assurance of operational readiness. In order for the licensee to perform the Code-required test, modification of the existing piping and valves would be required, which would impose a burden on the licensee and, therefore, relief is granted pursuant to 10 CFR 50.55a(g)(6)(i).
3.0 CONCLUSION
The staff concludes that the Code requirements are impractical to meet for RR-6, RR-7, RR-8, RR-9, RR 10, RR-15, RR-16, RR-17, and RR-30. Therefore, relief is granted pursuant to 10 CFR 50.55a(g)(6)(i). The relief granted is authorized by law and will not endanger life or property or the common defense and is otherwise in the public interest given due consideration '
to the burden upon the licensee that could result if the requirements were imposed on the facility. .
Pursuant to 10 CFR 50.55a(a)(3)(i), it is concluded that the alternatives proposed in RR-1, RR-2, RR 3, RR-4, RR-5, RR-12, RR-13, RR-18, RR 19, RR-20, RR-21, RR 22, RR 23, and RR 28 are authorized. Use of Code Cases N-521, N-524, N-509, N 498-1, N-416-1, and N-522 are authorized for the third 10-year interval at FNP Unit 1 and for the duration of the Unit 2 updated intervs!, or until the Code Case is approved for general use by reference in RG 1.147.
At that time, the licensee may continue to use the Code Case with the limitations, if any, listed
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! in the RG 1.147. SNC's proposed alternatives will provide an acceptable level of quality and l l safety and, therefore, the proposed alternatives are authorized. RR-14 is authorized pursuant l to 10 CFR 50.55a(a)(3)(l) for all components except for the VCT and RHE.
Pursuant to 10 CFR 50,55a(a)(3)(ii), for RR-11, RR-24, RR-25, RR 26 and RR-29, the staff finds that compliance with the Code requirement would result in hardship without a compensating increase in the level of quality and safety and, therefore, the proposed alternatives are authorized. However, RR 25 is authorized until the end of the first period of the l third inspection interval for each unit of FNP.
Principal Contributors: P. Patnaik A. Lee Date: January 12, 1999 l
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